A quarterly magazine from the National Association of Enrolled Agents
Winter 2024 vol.42 no.4
Say Goodbye to Most Form 5471 Penalties
Tax Court

Say Goodbye to Most Form 5471 Penalties

Alon Farhy used two Belize corporations to attempt to evade United States income tax. While he was not prosecuted for these actions, he also never filed Form 5471, Information Return of U.S. Persons With Respect to Certain Fore... Thomas Gorczynski, EA, USTCP

Summer 2023, Tax Court, collection due process, CDP hearing, §6038, Form 5471, §6038(b)(2), §6201(a), Letter 1058
Assessable Penalties and Abating Them
Feature Article

Assessable Penalties and Abating Them

The United States federal tax system operates on a system of somewhat voluntary compliance. However, human nature being what it is, a voluntary system without a means of enforcement lends itself to fraud, ignorance, and disregard. I... David Woods, EA

Sept/Oct 2021, Feature Article, §199A, penalties, fraud, §6038, §6662, accuracy-related penalty, Form 8858, Form 8938, §6651(a), §6651(a)(1), §6651(a)(2), §6663, Form 926, Form 5471, Form 8865, Form 3520, Form 3520-A, §6662(j), abatement, §6038D
What Jurisdiction Does the Tax Court Have Over Passport Actions Under §7435(b)?
Tax Court

What Jurisdiction Does the Tax Court Have Over Passport Actions Under §7435(b)?

Vivian Ruesch, Petitioner v. Commissioner of Internal Revenue, Respondent 154 T.C. 13 | Filed June 25, 2020 Vivian Ruesch (154 T.C. 13 (6/25/20)) provides the first Tax Court guidance on Internal Revenue Code (IRC) §7345, captioned “Revocat... Sherrill Trovato, EA, USTCP

Mar/Apr 2021, Tax Court, Tax Court, Passport, CDP hearing, §7345, Delinquent, Notice CP504, §6038, Ruesch, FAST Act